How To Know When A Tire Is Old



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Safety Research & Strategies, Inc. 340 Anawan Street / Suite 200 Rehoboth, MA 02769 Ph. 508-252-2333, Fax 508-252-337 www.safetyresear ch.net December 20, 2006 The Honorable Nicole Nason Administrator National Highway Traffic Safety Administration 400 7 th Street, S.W. Washington, DC 20590 RE: Comments on Tire Aging, Docket 2005-2276 Dear Administrator Nason: The following submission is a continuation of our comments on tire age degradation. 2 3 4 5 6 In these comments, we are submitting an updated list of real-world crashes resulting from tread separations in tires older than six years and addressing history of the current date coding found in the Tire Identification Number (TIN) and the need to provide a consumer-friendly date of manufacture. Safety Research & Strategies is a research, consulting and advocacy firm specializing in motor vehicle safety issues. We work with organizations and individuals who share our goals of improving safety and reducing harm in the motor vehicle and transportation environment. Our clients include lawyers, engineering firms, government, and corporations whose products enhance safety and reduce injury. Attached is a spreadsheet containing a list of 08 incidents in which tires older than six years experienced tread / belt separations most resulting in loss-of-control crashes. These incidents have caused 85 fatalities and 5 injuries. This list represents incidents that SRS has identified primarily through a survey of litigation, which is one of the only publicly available sources of these incidents. As we noted in our July 27, 2006 comments to this docket 7 the Early Warning Reporting (EWR) data, which is still only Docket 5400-2, September 7, 2003 2 Docket 5400-3 and 5400-32, November 5, 2004 3 Docket 2276-5; May 25, 2004 4 Docket 2276-9, August 4, 2005 5 Docket 2276-20 / Docket 250-69; July, 27, 2006 6 Docket 2276-27, September 28, 2006 7 Docket 2276-20 / Docket 250-69; July, 27, 2006

The Honorable Nicole Nason December 20, 2006 Page 2 available to NHTSA and not the public, excludes these incidents since Section 579.26 Reporting Requirements for Manufacturers of Tires only requires reports on tires that were manufactured less than five years prior to the claim. The attached case list consists predominantly of severe injury or fatality incidents in which there are significant economic damages. This is expected, as the primary source of these incidents is products liability litigation. The list does include several nonlitigation incidents that we have learned about; however, as the agency knows, most incidents that do not involve injuries or fatalities go undocumented and uninvestigated. Furthermore, the expense associated with pursuing products liability claims generally prevents lawsuits from being filed unless the damages are greater than several hundred thousand dollars. Because there is no economic incentive to pursue cases with lesser damages, many of the less severe injury claims potentially related to aged tires are not investigated, pursued or recorded in ways that are accessible. The end result is that the incidents SRS has documented in the attached list represent only a small percentage of the real-world problem associated with aged tires. Because litigation serves as a bellweather for trends, we suspect that aged tires are contributing to a significantly larger number of failures than those we have documented. It is striking that there is an absence of high-speed rated tires in the attached list. As we noted in our submission to the docket that included a statistical analysis of the Phoenix Tire dataset, high-speed rated tires are generally designed with a more robust construction to handle the increased demands that accompany high speeds. 8 This robust construction may have an impact on the performance of a tire as it ages. Features like high-halobutyl content inner liners and cap plies, among others, are known to have a positive effect on belt-edge separations and enhance the likelihood a tire will remain intact for a longer time increasing the probability it will wear out before a catastrophic failure. There are many reasons why aged tires may end up in service on a vehicle and many of these aged tires appear to be safe and serviceable. The Desanges case highlights the dangers of little-used or unused spares, which were the culprits in nearly a-third of the crashes in our list. In this case, the tire was an OE spare on a 994 Chevrolet G20 2- passenger van. The tire, a Uniroyal Tiger Paw, made during the 34 th week of 993, was placed into service prior to a trip between the Northeast and Florida. On the return trip to Florida, the tire suffered a tread separation and the vehicle became uncontrollable and rolled. Three occupants were fatally injured; a fourth was rendered a quadriplegic. In the Mizenko case, Bryan Mizenko purchased a 989 Bronco II in 200. At some unknown later date, the original spare, a FR480 made in the fourth week 8 Docket 2276-27, September 28, 2006

The Honorable Nicole Nason December 20, 2006 Page 3 of 989, was placed on the vehicle. In August 2003, the former spare experienced a tread separation, causing the vehicle to rollover. Mr. Mizenko suffered catastrophic closed head injuries and is also paralyzed. Because consumers and in many cases tire dealers and service centers have little information on the hazards associated with aged tires, there are circumstances in which old tires are often unknowingly sold or installed as new. Several of the incidents in the attached list typify this scenario. In the case of Javier Rene Garcia Sr., the right rear tire on his Honda Accord failed on July 30, 2005 while driving on Texas Highway 359 south of Realitos. Mr. Garcia s vehicle became uncontrollable and he struck a 200 Chevrolet S-0 pickup truck driven by Jonny Lee Woodall. The tire that failed was a -made Exxon branded Signature II made in 42 nd week of 99. The tire was purchased by the decedent several months prior to the crash from a local tire dealer. Mr. Garcia, his girlfriend, Jenilee Rodriguez and his seven-year-old son all suffered fatal injuries. Mr. Woodall suffered serious injuries. Ms. Rodriguez is survived by three minor children ages nine, seven, and four and are now being cared for by her mother. Similarly, Fertune Blanchard, 7 years old, was driving southbound on I-95 from her mother's house in Jacksonville, Florida back to her father's house in Tampa, where she lived and attended high school. She was driving a 200 Ford Explorer that her father had recently purchased for her when the tread on the vehicle's right rear tire separated causing the vehicle to become uncontrollable. The vehicle rolled over when it left the roadway and Fertune was ejected and killed. When the Blanchards purchased the Explorer, it had previously been fitted with a set of four matching XCLT4 tires. Three of the tires were made in the 35th week of 200, the remaining tire, and the one that failed, was manufactured in the 29th week of 994. All of the tires were manufactured at 's Nova Scotia plant. The accident occurred on May 29, 2006, making the subject tire approximately 2 years old at the time of the crash. There are many other examples of similar tragedies in the attached incident list. Again, these incidents underscore the immediate need for policies to alert consumers that tires have service limits beyond obvious and visible tread depth and for a regulation requiring non-coded dates of manufacture. On November 5, 2004 Safety Research & Strategies petitioned NHTSA to initiate rulemaking to require a consumer-friendly date of manufacture molded into tire sidewalls. Our petition requested that tire labeling rulemaking commence separately from the tire performance standards so as not to become mired in that lengthy process. As we noted in our petition, a simple date of manufacture will not conflict with other possible requirements, regardless of any future agency action on the issue of tire aging. Rather than consider this approach, the agency decided to lump this petition into the tire

The Honorable Nicole Nason December 20, 2006 Page 4 performance rulemaking and indicated it would be considered at some future date. The result is that the agency continues to delay addressing this issue at a key time before the new Tire Identification Number (TIN) rules are required and manufacturers have completed their investment in new molds. Since our 2004 petition we have examined in detail the origins of the TIN and have formed an even stronger opinion that it is important for the agency to act on this issue now. Following is a summary. The Tire Identification Number has its origins in a Rubber Manufacturers Association (RMA) system that preceded the National Highway Safety Bureau rule as the tire identification standard was promulgated. During the 38-year history of this rulemaking, the debates have focused on three main issues: () the contents and the purpose of the TIN; (2) its location; and (3) the record keeping associated with matching recalled tires to purchasers. The specific discussions regarding the date of manufacture code have occurred three times: () at the standard s inception; (2) in the late 990s and (3) during the last few years, when the agency sought to overhaul the rule in response to the TREAD Act. As is the case in many rulemakings, the regulated industry fought hard to shape the regulations. In the past, when tire recalls were relatively rare, and before the problems associated with tire age came to the forefront, tire-makers were successful in keeping the TIN an obscure set of alpha-numeric characters that even some tire sales and service employees couldn t decode. The Ford Explorer- tire recalls of 2000 and 200 provided the opportunity for regulators and manufacturers to reexamine the TIN. As the evolution of FMVSS 39 demonstrates, neither has finished the work of making this information accessible so that consumers can fully participate in recalls and make good purchasing and service life decisions. In 968, the RMA had devised its own tire identification code, which it presented in a series of meetings, to the U.S. House Finance Committee on Interstate and Foreign Commerce, as well as the NHSB. On May 8, 970, the industry trade group formally petitioned the federal government to adopt its tire identification system. 9 The RMA s proposed system consisted of an 8-9 alphanumeric code that would identify the week of manufacture, the manufacturer and specific plant, the tire size and basic type of construction. The date of manufacture was a two-symbol code devised by the RMA, which required a specially devised key to decipher. 0 9 Docket 70-2-No.-00 0 Docket 70-2-No.-00

The Honorable Nicole Nason December 20, 2006 Page 5 The federal government had established FMVSS 09 Tire Identification to devise a system in which consumers could be notified of a defective tire in the event of a recall. The NHSB s first proposals did not explicitly outline the consumer s role in the tire recall process. But it is clear from the comments of tire manufacturers that they did not believe the consumer was capable of being, or should be, an active participant. On July 23, 970, the agency opened Docket 70-2 with its own proposal to develop a standard identification number for tires that would be molded on both sides of the sidewalls. The NHSB proposed a system with four groups of symbols, to be read from left to right. This regulation would replace the manufacturer s assigned code marks under FMVSS 09 and the retreader s code number and retreading date in the label specified under the proposed retreaded tire standard). The first group of symbols would contain the manufacturer s identification mark, which would be assigned by the agency. Manufacturers of new tires would have a two-symbol mark; manufacturers of re-treaded tires would get a threesymbol mark. The second, two-symbol group would identify the size of the tire. The third group, consisting of four symbols, would identify the date of manufacture by week and year. For example, 37 would mean that the tire was made on the 3 st week of 97. The fourth group would be optional for manufacturers to more precisely describe the tire product name, load range, number of plies, etc design features which directly influenced the safety performance or structural integrity of the tire. 2 The RMA and many of its members were generally outraged that after two years of lobbying, their system was not adopted outright and they complained about every aspect of the proposed rule. On the issue of the date code, many acknowledged that it should be the first group of numbers, since it was important to make most conspicuous the most salient piece of information in identifying a lot of defective tires. Yet some didn t want the customer to be able to interpret the code, think they were capable of reading it, or believe that is was necessary for the consumer to have that information. BF Goodrich, for example, said that the consumer would be able to identify a recalled tire based on a defect notification letter that would use the entire serial number. 3 Goodyear said that it was questionable that the consumer would be any better able to decipher the bureau s proposed four-digit date code than the RMA s two-digit code. 4 in particular argued that the bureau should adopt the RMA s two-symbol date code expressly because consumers couldn t read it. Tires are not perishable items, said in its petition. Therefore, a conspicuous disclosure of tire age would Docket 70-2 No. ; 35FR 800; July 23, 970 2 Docket 70-2 No. ; 35FR 800; July 23, 970 3 Docket 70-2-No. -047; BF Goodrich 4 Docket 70-2-No.-036; Goodyear Tire & Rubber Company;

The Honorable Nicole Nason December 20, 2006 Page 6 unavoidably introduce into the marketplace a totally artificial measure of quality unrelated to product performance and effectiveness. 5 In November 970, the agency published a final rule that adopted some of the public s suggestions, but rejected many others. 6 The agency dropped one of the key measures most vigorously opposed molding the TIN of both sides of the tires, because of the alleged manufacturing hazard it created. The agency also agreed to drop that part of the proposal, because, it reasoned, under the consumer records part of the proposal, first purchasers of tires would receive notification of defects by certified mail. Under the final rule, the order of the symbol groups was also altered. The first group remained the designation of the tire manufacturer, with makers of new tires having a two-symbol mark; and re-treaded tire makers having a three-symbol mark. The second, two-symbol group would identify the size of the tire. But the final rule switched the third and fourth symbol groups. The third group could be used except when the tire is a brand name as an optional descriptive code of design feature, of which the manufacturer would maintain a detailed record, available to the Bureau upon its request (product name, load range, number of plies, etc.). The fourth group designating the build date of the tire would now consist of three symbols. The agency dropped the decade position, so that 3 would mean that the tire was made on the 3 st week of 97. The agency said that it shortened the date code and moved it to the last grouping to the last position to make it easier for manufacturers to shorten and change the stencil plate. The manufacturing date code remained a three-symbol group for 28 years. Then, on October 9, 998, the agency granted petitions from the RMA and the European Technical Rim and Tyre Organization (ETRTO) requesting that the grouping signifying date of manufacture be expanded from three digits to four digits (as was first proposed in 970) and that the minimum size of the numbers be reduced from 6 mm to 4 mm. 7 Both organizations argued for the change, in part, to harmonize the U.S. standards with those of the ECE in Europe. The agency agreed that this would help the traceability of defective tires and advance harmonization. On July 8 999, the agency finalized the rule change and set a July 2, 2000 effective date. 8 In the post Ford Explorer- tire rollover period, the efficacy of the TIN and other tire information would re-emerge. On December 9, 200, the agency published a Notice of Proposed Rulemaking to establish a new standard to the existing labeling requirements and addressed: the TIN; the tire markings, the vehicle placard content, format, and location as well as owner s manual information. NHTSA proposed 5 Docket 70-2-No.-076; The Tire & Rubber Company; 6 Docket 70-2 No. 2; 35FR 7257; November 0, 970 7 Docket 998-4450; 63FR 55863; October 9, 998 8 Docket 99-5928; 64FR 36807; July 8, 999

The Honorable Nicole Nason December 20, 2006 Page 7 that the TIN, size designation, maximum permissible inflation pressure and maximum load rating be placed on both sides of light vehicle tires. 9 In this round of rulemaking, the agency did not solely rely on tire-makers to characterize the knowledge and desires of consumers. Instead, it contracted a series of eight focus groups to determine what consumers knew about tires and safety and what they would like to know. The agency s research, which formed the basis of the proposal, found that consumers were confused by the codes, but wanted to learn more about what they meant. Among the specific findings of the study were: No more than one or two study participants had any understanding of more than a little of the information on tires. Some knew that they could find the tire pressure, tire type, weight and brand name. But few had any concept of the full range of information available. And no more than one or two could begin to explain the codes, ratings and other information. 20 Most study participants were perplexed by the array of alpha and numeric codes appearing on the demonstration tire. Although they suspected that the codes may hold interesting, even useful, information, none of the persons taking part in this study could identify or describe the meaning of the majority of codes, grades and scores. 2 Many want to know what the tire codes and ratings meant. Although some study participants indicated little or no interest in knowing anything more about tires than they already knew, a number expressed a desire to know more about the meaning of the information that appears on tires. Most said they felt it would make them merely better informed consumers. 22 Some study participants wish additional information were shown on tires. After they had looked at the information already contained on tires, some suggested that the following information was also displayed: Date of manufacture. Recommended replacement interval. 23 9 Docket 200-57; 66FR 65536; December 9, 200 20 Docket 200-57-07; Equals Three Communications; Tire Labeling Focus Group Report; May 4, 200 2 IBID 22 IBID 23 IBID

The Honorable Nicole Nason December 20, 2006 Page 8 Study participants wished that tire information were presented in plain language. Since they tended to believe that information provided on tires is there for a reason, they wished it was displayed in a more understandable format. Codes may be appropriate for the trade, they suggested, but not for consumers. 24 While this would indicate a clear direction for further refinement of the TIN, the agency stopped far short of moving toward a plain language standard. Instead, the agency s major proposals included re-ordering the TIN information and requiring that the information be molded on both sides. Less than a year after its initial proposal, NHTSA issued a final rule on tire safety information. 25 The final rule dropped the provision to mold the full TIN on both sides of the tire, out of consideration for the manufacturing hazards associated with changing the molds. However, the agency did require the TIN to appear on the intended outboard sidewall and either a full or partial TIN (i.e., one without a date code) appear on the inside sidewall. The agency also backed off its proposal to have the TIN reordered and eliminated size and format requirements for the vehicle placard and label. After tire-makers complained, NHTSA decided to delay the effective date from September, 2004 to September, 2005 for the vehicle and some tire labeling requirements. 26 More importantly, the agency eliminated the phase-in dates to put the TIN on the intended outward sidewall. Instead, manufacturers would have until September, 2009 to ensure that consumers could read the TIN on the outboard side of the tire. This was a concession to tire manufacturers who argued it would cost $224 million to re-work all of the molds. By pushing the date ahead five years, it would give manufacturers time for current molds to wear-out, before their replacement. The requirement to include the partial TIN (minus the date code) on the opposite sidewall was subject to the phase-in schedule, with 00 percent compliance by September 2007. As the rule stands today, consumers still have to wait three years before they get easier access the TIN. However, consumers are no closer to understanding what these numbers and letters mean. Meanwhile, when manufacturers are reworking their molds to comply with other aspects of FMVSS 39, they could also be incorporating a change in the date of manufacture to a format anyone can understand. Based on the above, we again request that the agency commence rulemaking on tire labeling to include a non-coded date of manufacture on both sidewalls. 24 IBID 25 Final Rule; 67FR 69600; Docket 2002-3678; November 8, 2002 26 Docket 2004-797; Final Rule; 69FR 3306; June 3, 2004

The Honorable Nicole Nason December 20, 2006 Page 9 Undoubtedly, the agency will hear about the alleged high costs and the limited real estate on a sidewall, and that the current TIN already provides the information requested. Tire makers have always played the high cost issue as the trump card. They have mounted this argument throughout the entire TIN rulemaking. However, while the industry is gearing up to place the TIN on both sides, the addition of a month and year instead of a 4-digit code within an alpha-numeric string is a nominal change. In our prior submissions to the agency on tire aging, we cited German reports from the late-980s that pointed to the disproportionate increase in failures in tires older than six years. We also cited articles and trade association agreements that clearly demonstrate that the industry recognized tires have a maximum service life, regardless of the remaining tread. Following NHTSA and Ford Motor Company s research, it is now clear that there is agreement that tire age matters and that oven-aging tests can reasonably simulate field aging. Now it s time to take the next step to ensure that consumers can immediately tell when a tire is too old. Easy-to-read expiration dates have long been standard on all sorts of products that deteriorate with age from foods and medicines to rubber washing machine hoses. Boston Brewing, the company that makes Samuel Adams beers, is an outlier in an industry that, like tire makers, routinely obscured their product s age with arcane codes. In one news article, Jim Koch, the company s founder, observed that the company printed easy to read best-by dates precisely because no store would only have fresh beer: The last line of defense is consumers, he said. 27 Tire consumers deserve clear, simple tire age information, or, as the agency learned when they surveyed average motorists, they have no defense at all. In summary: Real-world failures that result from aged tires are difficult to identify in publicly available datasets. Incidents that result in litigation tend to represent the most significant severity and injury crashes. The attached list of aged tire incidents is expected to have captured only a small fraction of the real-world incidents that have occurred. Even within the litigation realm, this list is clearly an under-accounting, as there are no over-arching datasets that capture these types of incidents. The incidents of aged tire failures underscore the immediate need for policies to alert consumers that tires have service limits beyond obvious and visible tread depth. Safety Research & Strategies has previously urged the agency to 27 The Search for Fresh Beer The Wall Street Journal, January 28, 2006, p.

The Honorable Nicole Nason December 20, 2006 Page 0 consider a Consumer Advisory on tire aging and the Ford Motor Company has supported our request. The current date coding contained in the TIN is a consumer unfriendly method for conveying important information that has clearly outlived its usefulness. Regardless of whether the agency decides that expiration dates are important, a born-on date provides meaningful information for consumers, thus we again request NHTSA to begin rulemaking, separate from tire performance, that would require the date of manufacture molded onto the tire sidewalls as an important interim step toward addressing tire aging issues. This date, in contrast to the current tire identification coding, should be in a format that is readily seen and easily understood by consumers. Sincerely, Sean E. Kane

Case Name Manufacturer Model Size Number Incident State Aldridge V. - Uniroyal- Goodrich BF Goodrich Trail Blazer 2 Incident City/ P205/75R5 MI Ingham DOT DOA Vehicle Vehicle Mk. Vehicle Mdl. Description Yr. AUULF3-20 9/4/999 990 Geo Tracker Original unused spare put into service after the owner had a flat tire. Shortly after owner's father took the vehicle to obtain a new tire for the vehicle (spare had less than 200 miles use), tire experienced a tread separation. Lost control and rolled. Used Tire Spare Tire Y Injury Total Fatality Total Andersen/Hill Dueler 684 P245/70R6 2 FL Made in LaVergne, TN, 45th week of 998 5/3/2004 Isuzu Amigo 998 tire was purchased new in 2003 approximately year prior to our wreck. Tread separation occurred causing Isuzu Rodeo to overturn multiple times. 2 Antoinette Bell V. Continental Tire Ataei-Kachuei v. Barnett v. BFS GT52S P205/75R5 3 CT Plainville Made in 988 6/29/2002 988 Ford Bronco II Tire was a brand new OE spare put into service when it was 4 years old and suffered a catastrophic tread belt separation within a short period of time. Subsequent loss-of-control rollover. Bridgestone 8.75 R 6.5 LT 4 NC Wake EKXK HHD084 0/7/2004 974 Chevrolet Truck Left front tread separation, causing rollover. Tire was sold as new 5/23/02 P75/70R3 5 TX Blanco H4FHDJE67 8/8/2004 986 Honda Accord Left rear tire separated, driver lost control rotated sideways across a lane and rolled. Y Becera Dunlop Remington XT 20 6 DHYE45223 /29/2003 993 Ford Aerostar Tire detreaded, vehicle became uncontrollable and struck a tree. Benivedes V. - Uniroyal Laredo P235/75R5 7 TX Ardmore, OK The tire was nine years old when it was placed on -Uniroyal- Uniroyal- plant, 3st week another vehicle. Subsequent tread separation. Goodrich Goodrich of 990 Blanchard v. XC LT 4 P235/75R5 8 FL St. John's B3DDBUYX294 997 Ford Explorer Four new matching tires were put on the vehicle about.5 years prior to the crash. One of the tires was years old at the time. Tread separated on the old tire causing the vehicle to lose control and roll. Brennan/Mizenko v. Bush v. Byrd v. Bridgestone FR480 P205/75R5 9 MT Cascade W2ULIML049 8/3/2003 989 Ford Bronco II Vehicle was bought used - had a 989 FR480 spare on it (vehicle was 2 years old at date of purchase). After being placed into service in the Left rear position, a tread separation occurred, causing rollover. Driver was ejected. Dueler APT P255/70R6 0 7BCUPUA438 999 Ford Explorer Bought used from a local mom & pop tire shop. Visual shows adequate tread depth. Four belted occupants, belted front ejected and killed. Bridgestone Dueler 684 P245/70R6 06S GA Y7MT 248 CBJ 248 8/6/2005 Spare tire was placed on rear of car in late July 2005. Tire tread separated, resulting in loss-of-control rollover. Y Y 2 2? Y 2 0 December 9, 2006

Cabrera V. Goodyear, Ford Castilleja v. BFS Castro v. BFS Cheung V. Goodyear Goodyear Vector P235/75R5 2 CA Tulare Unknown-- Vectors were last made in 99 8/5/999 995 Ford Explorer Tread separation on the rear of a 995 Explorer. Lossof-control rollover. Tires were discarded by the CHP before a DOT was noted. However, the Vector was last made in 99. Looking for service records to determine when the tire was put on the vehicle. Y 4 Uniroyal Laredo LT235/85R6 3 CA Made in 983 992 GM Pickup Tread separation caused driver to lose control. LRE Carver V. Uniroyal - Uniroyal- Goodrich FR480 P225/75R5 4 TX Hillsboro W2UUMX454 2/2/2004 994 Ford Explorer Left rear tread separation causing rollover/roof crush. FR480 P225/70R5 5 CA Palm Springs / Riverside W2UUMX38 6/0/2003 992 Ford Explorer Tire was supplied as a spare tire at the time of purchase in 9/200. Tire was put in service 3 days before the accident, which occurred 6/0/03. Uniroyal Tigerpaw P205/75R5 6 CA Fresno APULBB287 8//2002 996 Nissan Quest Tire bought at a dealer as a spare. Used as a spare in place of the temporary spare. Had a problem with one tire and moved the spare onto the vehicle. Experienced a separation within two weeks. During the separation vehicle became uncontrollable and rolled. Y 2 Y Cleworth V. Goodyear Goodyear Goodyear 7 FL Made in 986 5/5/997 Mack Dump Truck Goodyear truck tire on the left front of a Mack dump truck blew out causing loss-of-control. The vehicle crossed the centerline and struck an oncoming tractortrailer. The Mack dump truck was in a prior crash and had sat in a salvage facility for a period of time. After the repairs were made the tire failed after 50 miles of service Contreras v. BFS Road King Sport SR P225/70R5 8 CA Tulare W2UUR236 6/30/2003 Ford Explorer Vehicle rolls off road, following a left rear tread separation. Driver fatal (unbelted). The crash occurred in 2003 7 year old tire -- 4 to 5 32nds tread depth Crane v. Ford, Crum v. FR480 P205/75R5 9 CA Fresno FR440 P25/75R5 20 Ontario, Canada W2ULML338. 8//2002 988 Ford Bronco II 480 original spare on right rear, put on shortly before accident, 360-degree tread separation; rollover. Leeds W2HF4FA243 7/3/2002 993 GMC Safari Spare tire was sold by Sunoco station when it 4 years old. Vehicle owned by driver's father. Five years later, five kids travelling in the van when the right front tire experienced a tread separation, but didn't lose air. Was able to drive to a rest stop. Had the spare put on. Bought a new Uniroyal tire, put spare back in the rear. Left rear then detreads. This time vehicle lost control rolled over into an embankment. Tire has less than 30K on it and has 6/32nd tread left. Y Y 2 December 9, 2006 2

Delphia Bailey v. Rockbusters, Inc. Bridgestone M844 MX V-Steel 440/65R22.5 2 TX Blanco 3CB23HE098 0/2004 99 Ingersoll- Rand Drilling Truck This truck is a drilling rig that sees low mileage. The left from tire failed causing the vehicle to pull left and cross the center line of the highway (it was a two lane nondivided highway) and struck a Ford Explorer at the the A-pillar. Prior to the trip, company had inspected each tires--they showed no signs of cuts, nails, repairs and had ample tread depth. The failure was on the inside sidewall of the left front tire. Expert's initial opinion is that the cause was "rubber fatigue." Englehardt v. BFS Wilderness P235/75R5 22 AZ W2HL MO353 7/4/2003 995 Ford Explorer The tire was a spare on a 995 Ford Explorer. Tire was mounted on vehicle in March 2003. Tread separation occurred on July 4, 2003. Tread depth between 7/32 to 8/32. Y Espericuetta v. Continental Tire Estate of Acejeune Moise v. Continental 235/75R5 23 Mt Vernon in 995 975 Chevrolet Van OE replacement tire for Nissan Pathfinder. Purchased a swap meet--failed one hour after being put into service. Daytona S-R P25/65R5 24 VDVF DNA 038 989 Nissan Pathfinder Right rear tire tread separation causing vehicle loss-ofcontrol and rollover. Tire was specifically bought and put on the vehicle either day before or the day of the accident. Sold out of a local mom & pop tire shop. Figueroa ATX P235/75R5 25 Mexico Jalisko 353 2/20/2003 993 Ford Explorer Occurred just over the Texas border. Appears that the tire was a spare put into service. History of the tire is unclear. Tire remained inflated after separation. Y 2 Garcia v. Garcia v. Goodyear Frandsen v. Frank Longoria v. Cooper Tire Cooper Triumph Mastercraft Avenger Exxon Signature II SR 3x0.5R5 LT Goodyear Pathfinder Radial 3x0.50/R6. 5 26 ID Elmore P225/70R5 27 TX Grapevine / Tarrant VD60YWH353 5/3/2002 990 Dodge Ram Right rear tire separation on the Ram, causing it to lose control and strike the plaintiff's vehicle (995 GMC Jimmy). 4/7/2004 200 Ford Ranger 0 year old tire bought at used tire outlet. Placed on Ranger, suffered tread separation 6 months later. Vehicle subsequently rolled, door latch failed and plaintiff was ejected. 95/70R4 28 TX Duval W2RWE8942 7/30/2005 993 Honda Accord Vehicle suffered a right rear tread separation, causing it to cross into the opposite oncoming lane, where it was struck by another vehicle. Vehicle was severed in half from the front dashboard forward, and all three occupants were ejected. 29 PJXBND9V59 979 Plymouth Van Full tread depth. The tire was purchased used from a mom and pop dealer. It was purchased with another tire of same make, model, and DOT. It seems the tires were just stored for a long time. Tire is a 989. Y 3 Y Gonzales v. SF-375 P235/75R5 30 TX Bexar Y7BN DHN 228 7/6/2004 999 Ford Explorer Rear tire tread separation, causing rollover. December 9, 2006 3

Hall V. Ford and Continental- Continental- Heather Keeney V. Hernandez v. Ford/ Hill V. Ford, BFS GT52S P205/75R5 3 GA Talapoosa A3UL42H407 8/5/996 988 Ford Bronco II Tire was an unused spare on the rear of a Bronco II. It was 9 years old when first put into service. Catastrophic tread separation occurred after it was driven less than,000 miles--led to rollover. FR480 P205/75R5 32 OH Rossford 6/5/2002 988 Ford Bronco II Original spare tire on a 988 Bronco II was put into service about two months before the failure. Tire failed causing a loss-of-control rollover. ATX P235/75R5 33 Mexico 2 miles over the TX boarder at Progresso VNHL IMO 63 8/2/200 993 Ford Explorer Original spare was put on and subsequently suffered a separation. The vehicle was purchased through an auction during the recall. Sold with the OE spare which was never replaced. 72 P205/75R5 34 FL VNULHE087 6/6/2000 987 Ford LTD Tire was an unused spare on a 987 Ford LTD Country Squire station wagon. Spare was put on after tire on the right rear started "thumping." Tread separation occurred after one day in service. Y Y 2 Y 4 Y Howard, et al. V. Howeedy V., et al ATX 35 SC W2ULML458 8/5/200 989 Ford Bronco II Right rear tire came apart causing the driver to lose control; vehicle rolled over. Tire was original issue and had never been used before. Tread was good, but once tire failed it appeared to have dry rot. Y 3 FR40 P25/75R5 36 FL Oceoala VDMO4A477 3/2/2004 992 Ford Windstar Tire purchased used from a tire dealer just prior to the Y 2 crash with 8/32nds tread depth, no repairs or punctures. Tread separation after two months in service. Jackson V. Continental Tire Jackson V. Goodyear Continental- Grabber ST P235/70R5 37 AZ Maricopa ADM 2WH 036 8/0/2003 996 Nissan Pathfinder Left rear tire separated, causing loss of control and subsequent rollover. Goodyear Goodyear Wrangler P235/75R5 38 M6HL-FNHR-32 7/30/2000 997 Ford Explorer Tread separation resulted in a loss-of-control rollover. Vehicle was being driven by the owner's mother. 2 Janssen v. ATX II P235/75R5 39 AR Franklin Jones V. Cooper Cooper Tire Cooper Discoverer Radial AST 3x0.5 R5LT 40 UT St. George / Washington Josan Hicks V. Dunlop Grand Trek P265/70R6 4 CA San Dunlop/Goodyear, Bernadino Toyota, et al Katrina Owens V. Firehawk SS P235/60R5 42 AL Crenshaw VNHLMO24 5/29/2004 994 Ford Explorer OE spare was put into service. Tread separation resulted in a single vehicle rollover crash. Y 3 UT60CXW234 3/2/200 998 Toyota Pickup Tread separation causing loss-of-control. DB72A6376 7/6/2003 997 Toyota 4Runner Driver and son were moving from Florida to California. Prior to trip, Toyota dealer rotated the unused OE spare onto the right rear three weeks prior. Tread belt separation occurred causing loss-of-control and rollover. W2VL FH5 094 2/22/200 980 Oldsmobile Delta 88 Replacement tire on an Olds Delta 88. Left front tread separation caused a loss-of-control while travelling at about 60 mph. Vehicle T-boned an ambulance. Tire made in 994, sold in 999. Y 3 December 9, 2006 4

Keddington v. - Uniroyal- Goodrich BF Goodrich Trailmaker P235/75R5 43 UT Beaver UT on I5. Mile 3 BEHLWF0386 7/8/200 995 Chevrolet Blazer Vehicle was travelling at highway speed when the right rear tire separated. The vehicle went off the road and rolled and struck a Dodge van. Tire was inspected by a tire dealer less than one month prior to the crash. 8/32nds of tread depth left--no punctures or other damage. Kelly v. Land Rover, et al. Continental- Ameri 550 AS P235/70 R6 44 CA San Bernadino A308443258 3/8/2004 995 Land Rover Discovery Right rear tread separation causing loss-of-control and rolled over approx. five turns Kiney/Tucker V. Ohtsu Ladson v. Bridgestone Ohtsu Ohtsu 45 MD 984 4/2/996 99 Mazda MPV Tire was purchased used and placed on the vehicle in 996. Tread separation occurred, vehicle became uncontrollable and rolled. Lewis v. Cooper Cooper Starfire Flite Line IV P205/70 R5 Martin v. Martinez v. BFS Y Dueler P245/70R6 46 FL Duval Y7MTCBJ38 /6/2004 999 Isuzu Amigo This was a 6-year-old tire that had been the spare and had approximately 5,000 miles on it before the crash. It was the left rear tire Y 47 FL Lee U9MO85E 479 8/8/2004 999 Mercury Villager Tire looked almost brand new - perhaps a spare M+S ATX P235/75R5 48 FL Ford Y Desert Dueler 33x2.5x5 49 CA San Diego Mateo V. Cooper Cooper Cornell 700 HT P25/75R5 50 AZ Casa Grande / Pinal McGuire V. Dunlop Tire, Sumitomo Rubber EJFUCFN240 7//2003 990 Ford Bronco Right rear tire tread separation, causing loss-of-control and subsequent rollover. UTHBB73497, 7/25/998 99 Ford Aerostar 99 Ford Aerostar. Right rear tire tread separation Texarkana plant causing driver to lose control. Vehicle left the road and Maxwell v. rolled. Radial Baja LT235/85R6 5 KS Salina VD0RWC076 6/3/2003 99 Ford 5- Church van loaded with 3 passengers plus cargo, Widetrack LRE Passenger towing a single-axle U-Haul trailer. Left rear tire Club Van detreaded, causing loss-of-control and rollover. Sumitomo Dunlop SP4N 52 FL Made in 986 3/6/996 MG Midget Tires were on a MG Midget that was driven infrequently. Vehicle owner's brother was driving the vehicle when the left rear tire experienced a tread separation. The driver lost control of the vehicle but was able to maneuver it to the shoulder; however a semi-truck attempting to avoid the vehicle struck the MG. Miller V. Cooper, Ford Cooper Patriot Ultra Supreme 775 P235/75R5 53 FL 5th week of 992 3/29/200 996 Ford Explorer Tread separation, loss-of-control rollover. Mimmitt v. ATX P235/75R5 54 MS W2HL-IMO-334 5/3/2006 998 Mercury Mountaineer Appears that tire was bought secondhand. Right rear tread separation, causing rollover. Four of the nine occupants were ejected. 7 2 December 9, 2006 5

Moreno v. Moreno v. Continental Continental- ATX P235/75R5 55 CA Riverside Ameri-Tech ST P205/70R5 95S 56 FL Kissimmee / Osceola VDHL MO 254 5/24/2006 994 Ford Explorer The vehicle was found with three Goodyear tires (right front, left front and right rear) and only one ATX on the left rear. There was no spare tire on the vehicle. The DOT number indicates the tire was made several months prior to the vehicle build date--likely the spare. A3 MO FFA 253 4/5/2002 992 Oldsmobile Royale Tire & Rubber Co. plant in Mount Vernon, IL 25th week of 993. Tread separated, causing vehicle to cross into oncoming traffic, striking another vehicle and seriously injuring that occupant. Y 2 2 Munoz V., Ford Murillo V., Motors - Uniroyal- Goodrich ATX P235/75R5 57 TX Near Brady, TX Made in 993 4/2/2002 993 Mazda Navajo Tire was a slightly used OE spare on an Explorer. Put into service within two weeks, suffered catastrophic tread belt separation. Resulted in a loss-of-control rollover Uniroyal Laredo LT 235/85R6 58 ANORB005 7/0/2002 986 Chevrolet Sierra Classic Pickup Tire experienced a tread separation within about 5,000 miles of service. Y 2 2 Northview Fire Dept Goodyear 385/65R22.5 59 NC Northview 99 2004 992 Fire Truck Right front tire was original on fire truck. Travelling back from a fire tire separated (vehicle governed at 65 mph), took 600 feet to stop the vehicle--no crash. [Failed tire and companion being shipped to SRS] Oates V. Cooper Cooper Tire Cooper Lifeliner Classic M/S P225/70R5 60 AR Hope U9UUCU9293 8/4/2002 995 GMC Safari Tire purchased by a former Cooper tire employee at a Cooper company store in 996 in Texarkana. Tire was intended for a classic car that was being restored. Tires were mounted on the vehicle which was stored on jacks. At some point the tire was removed and stored in a garage and mounted on a GMC van--about 8 months prior to the crash (set of 4). First separation occurred on a rear tire, no crash. This tire was brought to Cooper, who replaced it for $.50 as it had virtually no wear. Second failure occurred on the left rear and resulted in a loss of control crash. Owens v. Uniroyal Tigerpaw 235/75R5 6 OK Wheeler ANHLHU247 3/6/2005 997 Ford Explorer The spare tire was rotated onto the right rear of the vehicle earlier in the day of the crash. The vehicle was travelling on the highway with 5 occupants when the right rear tire suffered a tread belt separation causing the driver to lose control. Vehicle rolled and all occupants were ejected (unbelted). Police report notes the spare tire was "dry rotted"--need more information. 2 2 December 9, 2006 6

Peralta V. All Weather Tire Sales, Ohtsu, et al Payan V. Ford, Continental- Pena V. Continental, Nissan Continental- Continental- Ameri 550 P235/70R6 62 Mexico Coahuila A30844347 7/7/2004 998 Ford F-50 Tire had 80% or its tread left when a separation occurred. Loss-of-control and rollover followed Ameri-trac P235/75R5 63 NC A3HL27V236 9/00/2000 987 Nissan Pickup Tire was an unused spare on a 987 Nissan Pickup. Was put into service and suffered a tread separation after one day of use. Vehicle lost control and rolled. Belted driver was in a coma for two weeks and was rendered a paraplegic. Ohtsu Falken 64 NY Tire made in July 988 995 994 Mazda MPV Tire was purchased new from a small retailer and put on the car in March 994. Tread separation Y Y + Pomering v. Prenger V. BFS P245/75R6 65 AZ Pinal AP70ILI I296 /24/2003 983 Chevrolet Pickup Tire was 7 years old (in Phoenix) on an old pickup truck that was bought by the claimant--the subject tire was on the vehicle when purchased with /32nds tread. Left front tread separation causing vehicle to swerve into opposing lane of traffic, hitting another vehicle headon. BF Goodrich Longtrail Bridgestone Dueler P24570R6 66 GA Turner EJMTJMM072 5/00/2002 992 Isuzu Trooper Original spare tire suffered catastrophic tread separation shortly after being put into service. Vehicle became uncontrollable and rolled. Y 2 Prince V. - Uniroyal- Goodrich Proctor V. Kumho Kumho Marshall Steel Belted Radial 77 Racca v. Goodyear Ramos V. Goodyear Radial X P25 75R/5 67 MO Saline 6/26/998 988 Jeep Cherokee OE spare was put into service. Tread separation resulted in a single vehicle rollover crash. 95/70R4 68 FL Lake Mary / Seminole YOJ9YAY374 8//200 983 Mercedes 300D Replacement tires were on the vehicle when it was purchased. Tread spearated causing loss-of-control rollover crash. Goodyear Wrangler HT LT225/75R6 69 LA Iberville MKIL26223 6/8/2000 997 Isuzu Rodeo Rear tire tread separation causing loss-of-control and rollover. Goodyear Kelly Springfield P275/60R5 70 PA Berks PJR7VAJ278 0/2/2003 983 Ford E50 Right rear tread separation causing loss of control. Turbo-Tech GT Vehicle crossed into oncoming traffic where it was struck on the passenger side be a Chevy pick-up. Tire made in Fayeteville, NC in 988. Tire was on the vehicle when he purchased the vehicle used in 998. Infrequently used vehicle. Y 2 3 Rios V. Goodyear Goodyear Kelley Safari AWR P25/75R5 7 TX PJHSKACR4 4/29/2000 994 Mazda MPV Tire was 0 years old at the time of the accident and found with 60 percent of its tread depth at the time of separation. Rivira Yokohama Medallist Radial A/S 72 TX Bexar CCHCVEA200 6//2003 988 Plymouth Voyager Travelling on I35, Left rear tread separation, loss-ofcontrol rollover December 9, 2006 7

Rocco V. Cooper Cooper Hercules Terra Trac Rodriguez/Reyes v. Yokohama Tire Yokohama Yokohama All Season 370G 33x2.5R6.5 LT 73 AZ UPXFHKX3882, 38th week of '92, Findlay, OH P205/75R4 74 TX Jim Wells 8/5/999 966 International Crew-Cab pickup 966 International Crew Cab pickup. Plaintiff was operating the vehicle when the left front tire experienced a tread/belt separation causing her to lose control of the vehicle, which left the roadway. Vehicle was used very infrequently. FDREMLN492 3/0/2002 990 Ford Aerostar Tire was on the vehicle when the vehicle was purchased used. Origins unknown. 2 Rowan V. BFS, Ford FR480 P205/75R5 75 FL Titusville / Brevard VDML09 2/9/999 989 Ford Bronco II Original spare tire was put into service on a 989 Bronco II and suffered a catastrophic tread separation within 2 weeks of operation (approximately 4,000-6,000 miles of total use). Traffic Homicide report noted that the tire looked new. Y Sanchez v. Sanders v. - Uniroyal- Goodrich BF Goodrich Radial Long Trail T/A 235/75R5 76 TX Shamrock ANHLHU247 2/6/2005 997 Ford Explorer Right rear tire (spare with dry rot) tread separation causing loss-of-control, rolled over approx. 5 times. All 5 occupants ejected. P225/75 R6 77 FL AP7HI47 8/29/2004 997 Isuzu Rodeo The tire looks to be a spare. Failed after 3 months of use. Y 3 2 Y Schifo Continental Ameri-Star 300SL P205/75R4 78 CA San Bernadino Mt. Vernon 993 (Full DOT illegible) /2/2002 999 Ford Ranger Right rear tire tread separation, causing loss of control and subsequent rollover. Driver ejected. Scifres v. BFGoodrich Radial R5 79 OK ANHLHU379 5/20/2005 997 Ford Explorer Tread Separation leading to rollover. 2 Long Trail Scudera V. BFS, Ford, Fuzzies, et al. ATX P235/75R5 80 FL Miami Dade 992 tire 6/2/2004 993 Ford Explorer Vehicle was purchased in Feb. 2002. Purchased four new tires, tire dealer advised that the spare tire was in good condition, no need to replace. Spare was put into service following a flat, appears to have been an OE spare tire. /32nds tread depth. Tread separation after two days in service caused a loss-of-control rollover. Y Shinhoster V. BFS, Ford Selling V. Continental- Continental- Continental GT 8000 P95/60R4 8 TX Near Wichita Falls ACR43EW407 7/29/2002 990 Acura Integra Tire separated (remained inflated), resulted in a loss-ofcontrol rollover. Seiberling P235/75R5 82 AL VDHLT3A463 6//2000 Ford Explorer Tire was purchased used in May 2000 for a spare. Was put into service shortly after. Tire failed with nearly 9/32nds tread depth. Siaw v. Continental Continental Contitrac AT P255/75R7 83 Ghana West Africa AD9C448357 3/8/2003 998 Ford Lincoln Tire Navigator Squires v. Sport King Radial A/T Medalist 32x.50R5 LT 84 MS Rankin The vehicle was shipped directly to Ghana, West Africa where the vehicle and the tires were stored in the client's enclosed garage. The vehicle would be used approx. 2-3 months out of the year (vehicle mileage was 2,479). On DOA, driver's side rear tire lost its tread, causing loss-of-control and rollover. BEYK TPJ 428 8/2/2004 984 Chevrolet Blazer Tire was four years old when it was sold new. Right rear tread separation at 6 years. Y December 9, 2006 8

Stevens / Kellermeyer v. Ford, BFS et al. Teamer v. FR480 P205/75R5 85 SC Camden HYUL80A347 8//2002 988 Ford Bronco II Left rear tire suffered tread separation, causing vehicle to strike guardrail and rollover. BF Goodrich Trail Maker P225/75R5 86 MI Perry BHHHL0328 7//2000 993 Chevrolet Astro Tire was manufactured in 988 and was a used tire sold from a Discount Tire Store in Battle Creek, MI. Left right tire blew out causing loss-of-control and rollover. Y 6 2 Tellez v. Pirelli Pirelli Sears Guardsman Rsponse XL P205/75R5 87 CA Riverside CKUL24C452 8/7/2002 993 Ford Astro Van Traveling at about 80 mph, right rear tread separation. Yawed left, went into the center divider, tripped and rolled. Two ejections. Believes that the tire was a spare (Madison, TN factory). Townsend Pirelli Pirelli P4 65R3 88 MO XPE9XJJX347 7//999 965 Sunbeam Tiger Tires were put on a restored Tiger that was stored on blocks and rarely used. The year old tires had about 4,000 miles in service when one experienced catastrophic tread separation. Led to loss-of-control rollover. Unknown 89 Scotland Made in 987 200 Peugot 205 Tire was put on a Peugot 205 by a Kwik Fit service center (owned by Ford) and was 4 years old at the time. Tread belt separation occurred, driver lost control and hit a minibus. Y? Valdovinos V. Challenger Regul P275/60R5 90 BER7N7HH488 996 Ford Explorer Tire was purchased used. Tread separation, loss-ofcontrol Y Sport rollover. Vera v. ATX P235/75R5 9 FL Orlando VHHL PB 284 5/8/2005 996 Ford Explorer Appears to be an OE spare. Right rear tire tread Y 4 separation, causing rollover. Four of the five occupants were ejected. Viel V. Kumho Kumho Marshal P75/80R3 92 FL Daytona 8/29/999 994 Toyota Tercel Left right tread separation causing vehicle to fishtail 2 Beach H2AU YPO 484 across the median, where it was struck on the right-side passenger door by another vehicle Vigil v. BFGoodrich Touring T/A Tubeless Radial P20570R4 93 TX El Paso 5/6/2004 956 Chevrolet Bel Air year-old tire purchased 0 years ago. Uncle bought tire and maintained receipts--from Pep Boys. Car sat in garage. 8/32nds on tire, no visual signs of deterioration. Gives them to a relative to put on a 56 Chevy--gets inspected 2 months prior to accident. Right front tread separation causing loss-of-control and subsequent rollover. Driver and front passenger ejected. 3 Ward-Lowery v. FR440 P235/75R5 94 MS Quitman HYHL4FA248 4/4/2004 998 Chevrolet Suburban Used tire, which was purchased on /23/2004 from a dealer, suffered a left rear tread separation on 04/4/2004 causing rollover, driver ejected. Y December 9, 2006 9

Wiest V. FR72 P25/75R5 95 AZ Fredonia / Mohave HYIIFF77033 6/27/2000 995 Ford Ranger Truck was purchased from an auto auction in Salt lake City on 5/9/00 and was sold with a 72 fullsize spare. The tire had almost full tread and showed no visible signs of deterioration. Sometime between the 5/9/00 and 6/27/00 the spare was mounted on the left rear. Tread separation occurred and led to loss-ofcontrol rollover. Unbelted driver ejected Y Wilkenson V. BFS Firehawk SS0 96 WY Albany Williams Williams et al, V. Pirelli/Armstrong, Sears - Uniroyal- Goodrich Pirelli- Armstrong Sears Ice & Snow Roadhandler P235/75R5 97 FL Suwannee 995 8/2/2003 978 Ferrari 308 GTB Left rear tread separation causing loss-of-control and rollover. Victim ejected. The 8-year-old tires were purchased with the car 9 days earlier from a Wyoming doctor who rarely used the vehicle. APHLF3U052 2/8/2002 992 Ford Explorer Tread separation on a 992 Explorer caused loss-ofcontrol and rollover. Tire had /32nds tread depth when it failed. P25/75R5 98 FL Alachua CKHF2FC376 5/8/200 998 Ford Windstar Experienced a flat tire while travelling on the highway. Purchased the subject tire used from a gas station. After completing the trip, the vehicle was inspected by a tire dealer who indicated the tires were fine. Drove on the tire for about two months before it experienced a tread separation (right rear). At the time of the failure the tire had an approximately 7/32nds. The vehicle became uncontrollable and rolled. Y 6 Williams v. Bridgestone Wilson V. Yokohama; Turner V. Yokohama; GM Bridgestone Dueler P245/70R6 99 FL Y7MTCBJ088 6/4/2005 998 Isuzu Rodeo Left rear tread and outer steel belt separation. The tire was the original equipment spare that was mounted on an exterior bracket on the rear of the vehicle. Approx. 2 weeks before the accident, the tire was removed from the spare position and placed on the left rear of the vehicle. On the morning of the accident the vehicle had a full service inspection, including a check of all tires, and got the all-clear. Yokohama (Mohawk) Mohawk 00 MO Wright City / Warren 984 [NEED Full DOT] Defendants claim the tire was made in Salem VA plant in 984 7//2002 970 Chevrolet C0 Unused Mohawk tires were purchased second-hand at a car swap meet and stored for several years before being mounted on a 970 Chevy C-0 Pickup truck. With more than 50% of the tread left, experienced a tread separation. Driver lost control crossed a median and struck another vehicle. Truck burst into flames. Young v. Cooper Cooper Courser LT245/75R6 0 UPBTU453 8/3/200 Tire failure caused driver loss-of-control, resulting in collision. Zamora v. Cooper Cooper Sumitomo SC990 P235/75R5 02 TX Charlotte UTHLWRA- 4-8/8/2004 993 Ford Explorer Left rear tread separation causing rollover. Two A/S ejections, including driver. Zapalac v. ATX LT 03 VD 990 974 Ford Bronco Vehicle was purchased in 2005 - after a restoration. 3x0.5R5 Had four 990 ATX tires --several months after purchase experienced a tread separation. Rollover ensued. Y 5 2 December 9, 2006 0

Zarzaur Zuniga v. BFGoodrich FR480 P25/75R5 04 AL W2HFMM49 9/3/2003 997 Chevrolet Astro Tires were replaced by a dealer on a 997 Chevy Astro van on 8/9/2002 with FR480s. Within one year three of the tires experienced tread separations, two causing significant vehicle damage. Two tires were returned to Corp. following the claim procedure-- denied the claim and noted that the tires were made in 989 and should not be in service. P205/60R5 05 MX Matehuala AN UN NC 4/0/2005 2002 Chrysler PT Cruiser Right rear tire separation, causing loss-of-control and Excentia GT 90T M+S 488 subsequent rollover. Bridgestone Dueler 06 Made in LaVergne, TN, 998 998 Isuzu Amigo Had three replacement tires, original spare was rotated into service. Tread separation occurred shortly after the incident causing a loss-of-control and rollover. Y 0 0 2 07 UK 28th week of 987 Maple Leaf M+S DEFENDER SRX+4RADIAL 60s 5/28/200 990 Peugeot 205 4 year-old Peugeot 205, was involved in a collision with a minibus when one of the tires suffered a "blowout" and the driver lost control of the vehicle. The vehicle had been purchased by the insured on September 3, 999. The tire that suffered a blow-out had previously been fitted by a tire fitter at Kwik-Fit (a company owned by the Ford Motor Group) in March 200. It had been stored as the spare when the car was purchased. The date of manufacture of the tire is the 28th week of 987 and was therefore nearly 4 years old when fitted. P235/60R4 08 BH RI N 74 392 9/22/2004 Made by Uniroyal Goodrich at Kitchener, Ontario in week 39 of 992. The tire was sold in August 2004 by a tire dealer in Imperial, California. Full tread separation. Y 0 TOTALS 5 85 December 9, 2006